On Jan 17, 8:48*pm, wrote:
Approach lights are part of runway environment...

Then you are clearly wrong. The fact that you see the approach lights
certainly does not indiciate that you have any visibility. As I
mentioned before you can see the approach lights through the fog but
not be able to see the ground around the lights. So your statement
that seeing the environment demonstrates the visibility, if you
include the apporach lights, cannot be correct.

-robert, CFII